08-04-04

T

These notarized paper are to be added to

file of his Special Cohort Exposure. There is one for the F-
1 and one for the E-5. His file number is

Thank vou nm

98-09-04P93:45 Revp


Special Exposure Cohort Petition : U.S. Department of Health and Human Services | :
under the Energy Employees Occupational Centers for Disease Contro! and Prevention | :
lilness Compensation Act National Institute for Occupational Safety and Health | :

. . OMB Number: 0920-0639 Expires: 05/31/2007 | :
Special Exposure Cohort Petition — Form B Appendix — Continuation Page | :

Continuation Page — Photocopy and complete as necessary.

The differences in exposure levels reported between IAAP workers and Pantex workers
suggest a technological or monitoring problem, as do the increased exposure levels seen at
the IAAP from 62-67 as compared to after 1968. The explanations proffered by the health
physicist at the NIOSH/DOL meeting with workers in Burlington refiect an obvious bias that
the difference in exposures documented could only reflect a difference in dose with no
acknowledgement of a potential for technologic or reader error. The possibility of
underestimation of dose seems to be real based upon technologic limitations, lack of
validation and variability noted in the data. It does not appear to be possible to recreate
the range and scope of potential exposures to this workforce without concurrent exposure
data from this site with adequate quality assurance nor relevant scientific experimental
data with adequate controls. The fact that there has never been a radiation incident report
in over 25 years of operation is odd and implies a lack of recognition and or reporting as
well as insufficient exposure monitoring.

Certainly the fact that there was no health physicist per se at the IAAP is telling especially
given the large staff devoted to Environmental Health and Safety at the Pantex plant
currently. Reportedly there are seventy, (70), plus technologic staff devoted to radiation
safety at Pantex not to mention Industrial Hygiene and other EH&S staff. This large number
of radiation safety staff seems to reflect a great change in the recognition of the hazard
and risk imposed by this work.

This workforce reported never using lead aprons when near or handling pits. The NIOSH .
site profile for the Pantex site reports on page 15 of 17 (ORAU-TX8S-0013-2) that workers
wore lead aprons because: “Direct handling of pits can result in high dose rates.” This
strikes us as a clear assumption by this Health Physicist author of increased risk associated
with handling pits without worker protection at Pantex, a situation that was the norm at

the IAAP.

What badge data is available is suspect for several reasons as noted above (lack of
validation etc., inconsistency with PANTEX, inconsistency over time, vast majority exposed
not monitored, etc). In addition, these badges were worn on lapels at a greater distance
from the pit than the workers’ abdomens, pelvis and arms.

Similarly what neutron dose data exists may have been underestimating exposure due to
neutron fading (monthly or multi-month monitoring as opposed to weekly or biweekly
lengths of monitoring).

The site profile appears to rely too strongly on too few respondents, too few and possibly
the wrong individuals and/or too few job tasks monitored (disassembly).

Name and social security number of first petitioner:
Page 7 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
ness Compensation Act Nationa! Institute for Occupational Sefety and Health

OMB Number; 0920-0638. Expires: 08/51/2007

Complete atleast one ofthe following entries in his section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.4 $B WWe have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personel monitoring or through area
monitoring.

(Attach documents and/or affidavits fo the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached

documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored.
SEE ATTACHED EIGHT PAGES

F.2 WW I/We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term,-or process
from the site where the employees worked.

{Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been lost, altered illegally, or destroyed.
THIS TOPIC IS COVERED IN THE EIGHT PAGES ATTACHED TO

THIS FORM.



8-04-04

My dad worked on line 1 at the I.A.A.P. as a fe was
witness to many test firers of nuclear weapons. Afer the firers
he would walk threw the area. He would lay on the floor, where
there was dust from the weapons, that was everywhere. He would
come home from work with that dust all over his clothes. I
remember one time in the 1960,s he came home from work and told
me to get something small, so he could put this gray powder

in that was in his pants cuff. I did know what to get him to
put it in and dad told to get a pop cap. I fold one and, he

He put the gray powder in it and set it on the window sill.

He told us never to touch it. I thought he said it was C5. He
He said it was very dangerous. They did not supply dad with
work clothes. He wore his own clothes.

I can not tell you about any of dad coworkers. They are dead
from cancer.

Thank you

“7 y



08-12-04 Aii:42 IN

Special Exposure Cohort Petition US. Department of of Health and Human Services
under the Energy Employees Occupational for Disease Contro! and Prevention
Sliness Compensation Act National inotiuts for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B of7

Survivor informatio
Name of Survivor

Quryitrs is. 8 Hoe ene Miadle Initial Last Name
B.2 Social Security Number of Survivor:
B.3 Address of Surviver-

B.1

g ane P.O, Box
City . i ‘State ers aneven

B.4 Telephone Number of Survivor:

B.5 Email Address of Survivor: 2

BS Relationship to Employee: Q Spouse Q Son/Daughter Q Parent

Q Grandparent .

Q Grandchild

Employee information — Complete Section C UNLESS you are a labor organization.

C.1 Name of we we - : ;

in, Ms. First Name Middle Initial Last wame
C.2 Former Name of Emplc: se (e.g., maiden name/iegal name change/other):
SAME
Mr/MrsJMs, First Name Middle initial Last Name
C.3 Social Security Number of Employee:
C4 Addrace nt Emp wet ele
Sire ° ante P.O. Box
oy sume ep Use
C.5 Telephone Number of Employee:
C.6 Email Address of Employee: LY A

C.7 Employment Information Related to Pefifinn-
C.7a Employee Number (if known): ~~

C.7b Dates of Employment: Start z 4 End
C.7c¢ Employer Name:
C.7d Work Site Location:

C.7e Supervisor's Name:

Name or Social Security Number of First Petitioner:


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational _____ Centers for Disease Control and Prevention

Itiness Compensation Act National Institute for Occupational Safety and Health
2 OMB Number: 0920-0639 Expires: 05/31/200'

Special Exposure Cohort Petition — Form B “a Pareoey

F Basis for Proposing that Records and Information are inadequate for individual Dose —
Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.1. Q WWe have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area
monitoring.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavii(s) indicate that potential radiation exposures were not monitored.

F.2  ® I We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there Is no information regarding monitoring, source, source term, or process
from the site where the employees worked. aa :

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been lost, altered itlegally, or destroyed.

They did nat provide hese sakhjsTa
ta Cl .

Name or Social Security Number of First Petitioner: _“ 7



Special Exposure Cohort Petition .. U.S. Department of Health and Human Services | :
under the Energy Employees Occupational Centers for Disease Controi and Prevention | :
tiness Compensation Act National institute for Occupational Safety and Health | -

. vas OMB Number: 0920-0639 Expires: 05/31/2007 | :
Special Exposure Cohort Petition — Form B .__ Appendix — Continuation Page | ©

Continuation Page — Photocopy and complete as necessary.

No records have been found that document the radiation sources, source term, uniformity
of exposures, potential for airborne dispersion, radiation energy spectrum, particle size
distribution, etc. that were in the work area with the employees on a day-to-day basis at
the plant. Detailed information of this type with chemical form of the radionuclide would
be required to validly reconstruct past radiation exposure. It is understandable because of
the tight security that much of this information was not maintained.

Reports indicated occasional sampling for Cesium-137, but no work process ever reported
use of this radionuctide. There may have been other exposure scenarios without
documentation.

There were 20 plus years when virtually no one was regularly monitored and thereafter
monitoring was was still limited to subsets of employees leaving out large groups of
exposed workers, (i.e. those doing disassembly tasks who apparently were never
monitored), Film badge records for external whole body radiation only exist for the years of
1965, 1966 and the years 1968 to 1975. Technicians checking the explosive wave lenses
by X-ray wore most of the film badges. No data is available on work related diagnostic x-
ray and gamma sources, which were a large part of the quality assurance process.

YEAR PEOPLE

1965 46
1966 51
1967

1968 176
1969 211
1970 288
1971 399
1972 432
1973 400
1974 173
1975 33

There are no records of hand and arm exposures. Hand and arms would undoubtedly get
more external radiation exposure followed by pelvis and torso.

In many cases, the external dose records indicate readings of zero. It is unknown whether
this indicated no significant readings above minimum detectable levels or whether there
were other problems with the data (such as a missing detector, etc).

Only about 20% of the workforce identified as Line 1 workers were ever issued film
badges-by estimates. The limited monitoring points out the minimal recognition regarding
safety since all the work force was at an increased risk of exposure.

Name and social security number of first petitioner:
Page 3 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Eneray Employees Occupational Centers for Disease Control and Prevention

lliness Compensation Act National tnstitute for Ocoupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 7 of7
Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
‘including suggestions for reducing this burden, send thern to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-XXXX. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C, § 552a), you are hereby notified of the
following:

The Energy Employees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Contro! and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupational Health Epidemiological Studies and EEOICPA Program Records,
HHS/CDC/NIOSH." These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to mak... for the processing of your peti''on or other purposes are fisted
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to all forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to
provide required information may not be considered by HHS.



Speciat Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Wines Compensation Act National institute for Occupational Safety and Health

. OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3 @ WWe have attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the faciiy, as relevant io the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dase reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation
guidelines.

(Attach report to the back of the petition form.)

F.4 (2 UWehave attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a fack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

(Attach report to the back of the petition form.)

All Potitioners should sign and data tha petition, A maximum of three persoris may sign the petition.

e- Lf F-OY
Signature
Signature Date
Signature Date
Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of

fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal! provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true. .

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention

IRness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 05/31/21

Special Exposure Cohort Petition —- Form B Page Sor

F.3. @ IWehave attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation
guidelines. .

(Attach report to the back of the petition form.)
F.4 (1 UWehave aitached a scientific or technical report, issued by a government agency of the

Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of

employees covered by the petition.
(Attach report to the back of the petition form.)

G Signature of
All Petitionarsi should sian and date the petition. A maximum of three persons may sign the petition.

; £-/67- 4 4

Signature , * Date

_ i B-f4-3Y
Sionaura . Si” Date

‘ 0 ny i A awd eo re) S|

- — we - 2

Sr ‘aur 7 ; i : . Date

Notice: 7 Any person who knowingly makes any false statement, misrepresentation, concealment of

fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true.

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Social Security Number of First Petitioner: _¢



Special Exposure Cohort Petition . U.S. Department of Health and Human Services | :
under the Energy Employees Occupational Centers for Disease Control and Prevention | ©
illness Compensation Act National institute for Occupational Safety and Health | -

OMB Number: 0920-0639 Expires: 05/31/2007 | :

Special Exposure Cohort Petition — Form B Appendix — Continuation Page | :

Continuation Page — Photocopy complete as necessary.

According to the NIOSH, no records have been located that indicate any individual
monitoring of internal doses of radionuclides (i.e. plutonium, uranium or tritium) occurred
between 1947 and 1975. No wrist or finger monitor data exist for these workers.
Furthermore, between 1947 and 1955, no dosimetry badges at all have been located to
indicate the doses of external penetrating radiation to which such workers were exposed.
Finally, records indicate that only 8 to 23 workers in a workforce of over 1,000 were
monitored for external radiation doses between 1955 and 1962. Even at the high point of
screening at the Iowa Army Ammunition plant from 1970 until 1975, only 20 - 25 percent
of the workforce were screened for exposure to external radiation and none have records
for internal dosages.

It appears that there is on one hand a scientific rationale to strongly suspect that handling
of plutonium or mixed fissile material pits would have put this workforce at increased risk
of cancer from ionizing radiation. On the other hand, there is insufficient documentation of
past radiation sources and processes to reconstruct past radiation dose with any validity for
these workers. If doses are reconstructed based on poorly documented processes that
occurred 28 to over 54 years ago, the number and magnitude of assumptions needed to
arrive at a “reconstructed” or estimated dose surely precludes the validity of such an

estimate.

The following paragraphs list just some of the deficiencies that make accurate or even
worst case retrospective dose assessment impossible with any degree of confidence. A
major concern is that there is so very little information documenting even the record
keeping procedures and methods that were historically used to censor data and
administratively assign dose.

r diation E: essment P: 7:

Several area monitoring records have been located that document the potential for high
external radiation exposure even though the location of these area measurements were not
in proximity to the actual immediate work area where higher exposures took place. Data
from area monitoring in this facility documents cases of exposure in excess of OSHA
standards. The 23-39-21 Yard C storage building had a yearly average of 18.2.rem. The
1-73 storage and receiving building had a yearly average of 16.9 rem. The 23-39-21 Yard
C storage building had a yearly average of 14.6 rem. The 1-77 storage and receiving
building, which replaced the 1-73 storage area, and receiving building had a yearly average
of 11.7 rem. The 23-39-7 Yard C storage building had a yearly average of 7.8 rem. It
would appear obvious that workers in such areas would be in significantly closer proximity
to the radiation sources than monitors on the walls

Unfortunately, documentation is non-existent regarding even general protocols for area, or
even personal, exposure monitoring. :

Name and social security number of first petitioner: ~ :7 _
Page 2 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
liness Compensation Act National institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
P 10f7

Genera! instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT all information clearly and neatly on the form.

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there is more
than one petitioner, then each petitioner should complete those sections of parts A — C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-
pose. A maximum of three petitioners is allowed.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach the completed continuation page(s) to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
request to speak to someone in the Office of Compensation Analysis and Support about an SEC petition:
4-800-356-4674.

QA Labor Organization, StartatD on Page 3

Ifyou QAn Energy Employee (current or former), StartatC on Page2
are: QA Survivor (of a former Energy Employee), StartatB on Page2

. SY A Representative (of a current or former Energy Employee), Start at A on Page 1
A. Are you a contact person for an organization? {& Yes (Go to A.2) Q No (Go to A.3)

A2 Organization Information:

Name of Organization

Position of Contact Person
AS Name of Petition Representative:

MrJMrs./Mis. First Name Middie initial Last Name
A4 Address:

Street Apt# P.O. Box

City : State Zip Code

A5 Telephone Number: ( ) _—

A6 — Email Address: Le . - en a

AZ Q Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization
form for this purpose is provided.



Special Exposure Cohort Petition . U.S. Department of Health and Human Services | :
under the Energy Employees Occupational Centers for Disease Controi and Prevention | ©
llttess Compensation Act Nationa! Institute for Occupational Safety and Health | -

. 7 OMB Number: 0920-0639 Expires: 05/31/2007] :
Special Exposure Cohort Petition — Form B Appendix — Continuation Page | :

Continuation Page — Photocopy and complete essary.

No documentation exists concerning where the background/control dosimeters were stored
and how background subtraction for detectors was performed and validated.

There are no records documenting whether or not a single generic background track
density was used for all buildings and all personnel.

There are no records to indicate how much surface area of the film from the badge was
evaluated. This would help determine the precision of the measurements.

There are no records regarding whether any neutron spectra measurements were made in
the areas where the workers handled the material to assure that the detectors could

measure all the relevant spectra.

No routine dose rate survey data has been located from either the radiation monitors or
health physics technicians using gamma dose rate instruments and neutron dose rate
instruments.

No data are available to indicate that adjustments were made to account for dosimeter
responses to low energy radiation.

Curiously, not one radiation related incident or investigation report was included in the
IAAP plant records for the entire period 1945 to 1975. Perhaps more disturbing is that.
there are records documenting contamination such as the collection and transport of
clothes to Pantex for plutonium contamination, but no information regarding personal
exposure to the people wearing the clothes. The question of whether plutonium exposure
was possible given this history of possible clothing contamination and worker histories of
early weapons handling is troublesome. The implication of no radiation incidents is
that monitoring was not as rigorous and potential for risk was much greater than
reported in the original site profile for this site.

internal Radiation Exposure Assessment Problems

Internal radiation dose assessment is an essential part of retrospective radiation dose
assessment. However, no documents have been located to either document protocols to
assess internal doses (analytical methods, detection limits, interferences) or that report

findings.

While we have first hand accounts that workers were monitored for internal body burdens,
no radiation dose estimates related to internal radionuclide body burdens were ever
entered into any of the dose records for the workers.

There must have been significant potential for internal exposure since at least one
technician reported performing urinalysis since the early 1950s. However, the technician
indicated the urine was only monitored for tritium.

Name and social security number of first petitioner: *
Page 5 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services |:
under the Energy Empioyees Occupational Centers for Disease Control and Prevention | :
Illness Compensation Act Nationa! Institute for Occupational Safety and Health | :

. ; OMB Number: 0920-0639 Expires: 05/31/2007 | :
Speciai Exposure Cohort Petition — Form B Appendix — Continuation Page | =

Continuation Page — Photocopy and complete as necessary.

Several groups of employees, who worked in close proximity to the fissile material, or pits,
were only occasionally, and often never, provided film badges to document external
radiation exposure. These groups include: The Physical Security Management Staff who
were responsible for receiving and supervising transport and storage of pits and gases.
The Safety Department personnel, the transport staff, a variety of tradesmen, (largely
mechanics who performed a variety of tasks in the production areas) and guards of the
Physical Security Department who roamed the entire area.

Personal interviews of production workers also indicate that even if badges were provided,
they often were not worn by these workers in the bays, with the supervisors’ knowledge,
but were left either in their lockers or on a main storage board.

For the years where radiation reports are available, the accuracy and the precision of the
readings are very questionable. ,

The radiation detectors used during the time period of work at IAAP were not very accurate
and poorly reflected actual employee exposure in most cases. A report* as recent as 1981
of controlled exposures indicated that film dosimetry lacked both precision and accuracy
and yielded underestimates of true neutron exposure approaching 80% in some instances.
The film from the 1950s through mid 1970s produced even less accurate and precise
estimates of the true personal exposure. For example, a study** of film detector
performance performed by Pacific Northwest Laboratories for the Atomic Energy
Commission. as late as the mid 1960s documented that the relative error of the film badge
for common types of x-ray and neutron exposure exceeded 500%.

By report from senior Health Physicists involved with AEC work during this era, spot checks
of the film in the radiation records files indicated that the original reads were suspect. In
this spot check it was determined that neutron doses may have been under reported by a
factor of 5 to 10 times. There are reportedly several news Paper articles on this topic in the
Rocky Mountain News Paper probably in the 1993 - 1996 time frame. Reportedly as a
result of questions regarding accuracy of neutron detectors at Rocky Flats DOE-RFFO felt
that is was imperative to initiate the Neutron Dose Reconstruction Project (NDRP).

*Sims, C.S., Swaja, R.E. personnel Dosimetry Intercomparisons Studies at the Health Physics Research
Reactor: A Summary (1974-1980). Health Physics, 42(1): 3-18, 1982.

**Larson, H.V, Unruh, C.M., Beetle T.M., Keene, A.R. Factors Involved in Establishing Film Dosimeter
Performance Criteria, in Radiation Dose Measurements, Their Purpose, Interpretation, and Required Accuracy in
Radiological Protection. European Nuclear Energy Agency, pp. 191- 208, 1967.

There are no reports of radiation detector calibrations or the existence of calibration films
(e.g., films with well-documented delivered neutron doses). These are required to assess
the accuracy of the detectors. The wife of the primary on-site detector
repairman/calibrator reported that her husband died at an early age from cancer.

Name and social security number of first petitioner:
Page 4 of 8 pages


Special Exposure Cohort Petition :
under the Energy Employees Occupational ; Centers for Disease Controt and Prevention | :
Hiness Compensation Act £ al Institute for Occupational Safety and Health | :

. . ‘GHB Number: 0920-0639 Expires: 05/31/2007 | :
Special Exposure Cohort Petition — Form B Appendix — Continuation Page | :

Continuation Page — Photocopy and complete as necessary.

I would like to give a bit more background and detail regarding the rationale behind the
Petition for Special Exposure Cohort Status for the Iowa Army Ammunition Plant,
IAAP/BAECP, workforce.

Throughout the DOE collaborative agreement: Former Worker Program for AEC/DOE
contract workers in the Middletown, Iowa, IAAP there have been amazing opportunities to
hear the firsthand accounts of these IAAP workers as regards their tasks and exposures.
Energy workers located at the Iowa Army Ammunition Plant (also known as the Burlington
Atomic Energy Commission Plant) were exposed to uranium, plutonium, and tritium, (and
possibly other radionuclides), in the course of assembling and disabling nuclear weapons
from 1947 until 1974.

This DOE facility (one of only two in our country doing these particular tasks) was
responsible for assembly, disassembly and repair operations of various nuclear weapons
from various sources. The process involved assembly of weapons components arriving
from other facilities, manufacture of high explosives components of said weapons and a
variety of repair or modifications processes. By workers’ memories it would appear that
teardown and repair work was a large portion of the work at times and that such work was
often done on weapons initially assembled at Pantex.

A large fraction of these IAAP workers worked directly with or in very close proximity to
hand held radioactive plutonium “pits” of these weapons. These were the innermost
radioactive or fissile components of atomic bombs consisting of critical masses of plutonium
and other metals with unstable nuclei selected for their properties of emitting
“radioactivity”. Many of these workers report holding the pits in their hands with only
cotton gloves with rare or no radiation monitoring and little or no shielding from the
radiation, (no glove boxes or lead aprons).

Personal interviews of production workers also indicate those even if badges were
provided, they often were not worn by the workers in the bays but were left either in their
lockers or on a main'storage board so they would not lose them. It should be noted that
when badges were worn as directed, it would have been at the lapel thus placing the film
badge at a greater distance from the pit than the workers’ torso and pelvis would have
been. In addition, only a small minority (approximately 20 percent) of the Line 1
workforce (Line 1 was the designated DOE line) were ever issued badges and there were
periods when none or very few individuals were monitored.

The NIOSH Site Profile provides documentation that the radiation exposure assessment
was incomplete and inadequate. Exposure data is sorely lacking and the Health Physicists
made a variety of assumptions in the site profile process. Where data are non-existent,
extrapolations of exposure where made using other facilities from other eras involved in
other manufacturing processes.

Name and social security number of first petitioner: ©
Page | of 8 pages


08-04-04—-

My dad - ----- did not have a monitoring badges issued
to him, He had no way of knowing if he got to much radiation.
He worked in all the area of line 1. He had clearence to the _
whole line because he was a . - » He should have had a
badge to determine how much vadiation he got. They did not
offer him one. I do not know why they would not issue a badge.
They are still cleaning up line 1, They are now talking about
burning the building. The radiation is still there.so how can
they say he didn, get Yadiation, when it is still out their
after all these years? How can they judge someone when they
have no proof? How can they compare someone to another person
when they didn,t do the same work or be in the same plant?
The. way you can treat my dad fair is put him on the Special
Cohora Exposure and approve him.

Phank you



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
ness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 05/31/2007

40f7

E1 Name of DOE or AWE Facility: Burlington Atomic Commission Pl
£2 Lélitoh? WeuQTERARrRiAAANG na seuddd? 2ke The Towa

= Yards Cy Gy af
iring Sites, Burnin; d "B", Storage areas for pits.

E.3 List Job titles and/or job duties of employees included in the class. in addition, you can list by

name any individuals other than petitioners identified on this form who you believe should be
included in this class: A ALL
vel

E.4 Employment Dates relevant to this petition:

Start End
Start End
Start End
—,5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: 0 Yes No

lf yes, provide the date(s) of the incident(s) and a complete description {attach additional pages
as necessary): cs .



Special Exposure Cohort Petition ‘ U.S. Department of Health and Human Services :
under the Energy Employees Occupational Centers for Disease Contro! and Prevention | :
Itness Compensation Act Nationa! Institute for Occupational Safety and Health | :

. OMB Number: 0920-0639 Expires: 05/31/2007 :
Special Exposure Cohort Petition — Form B Appendix — Continuation Page | :

Continuation Page— Photocopy and complete as necessary.

The issue of “cladding” or shielding is unsettling. From worker interviews it appears likely
that not all pits were “clad” in beryllium and/or depleted uranium. There may well be
situations by which workers would have had potential for exposure to poorly clad pits. One
was in the assembly of the Mark 6 weapons during which workers reported handling a
hollow sphere in the core of the assembly and handling a threaded cap that could close this
central portion of the assembly. They stated that this assembly unit required an “initiator
unit for arming” which was placed in flight. These workers reported running their bare
hands along the inside of this hollow sphere to ensure it’s smoothness and cleanliness. In
addition by workers’ report, the reported frequent dismantling of pits apparently may have
- in some early configurations - involved removal of the metallic hemispheres covering the
pits in addition to removal of the high explosive “lens” coverings. Certainly the heat
emanating from these pits as described routinely by these workers implies at least internal
alpha radiation in these pits and presumably poorly characterized neutron and gamma
radiation as well. The additional questions of the efficacy of the various forms of cladding
and the potential of beryllium elements of the cladding to act as neutron sources
themselves or even just to slow neutrons down may have significant undetermined impact
on the risk to workers from ionizing radiation.

This special energy cohort is a predominantly elderly group of retirees, many with high
rates of suspected work-related diseases including reported cases of Glioblastoma, Other
Brain Cancer, Leukemia, Lymphoma, Thyroid, Lung, and Bladder Cancers and
Pneumoconiosis in addition to the expected plethora of more common diseases.
Approximately twenty-five of these workers have died in the last year and a half. We have
had over 500 claims for radiation induced cancers arise from our facility and none have
been accepted yet on the argument that there is not sufficient evidence for radiation
exposure, Many of these workers will not survive the anticipated process of dose
reconstruction. These claimants and their families are seeing their faith in their
governments’ intentions eroded by the current process which is operating so slowly that
claimants are dying much faster than claims are being processed.

On the basis of these concerns regarding the completeness, adequacy, and accuracy of
both the available exposure assessment records and work practices and on the rational
assumption of risk based upon direct handling of plutonium pits and pit containing
weapons, we suggest that dose reconstruction cannot yield valid information. Special
Exposure Cohort Status ought to be granted to this IAAP cohort who routinely
worked in close proximity to radioactive sources and became ill ~
Sincerely, \ iN

a
“OFFICIAL SEAL”
Anthony S. Jovanovich
Notary Public, State of ilinois
DuPage County
My Commission Expizes 11/20/2607

Rant ove RB.

Name and social security number of first petitioner:
Page 8 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Miness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 4 of 7
on of Employee C covered by Petition — Complete Section E.

E.1. Name of DOE or AWE Facility: Atomic Energs Commissita P47
E.2 Locafions,at the Facility relevant to this petition:

E.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be
included in this class:

| oF

E.4 Employment Dates relevant to this petition: 7

Start _ End.
Start End
Start End
E.5__ Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: WW Yes Q No

If yes, provide the date(s) of the incident(s) and a complete description (attach additional pages
as necessary): :

pr — He had 70 _moniterin corde,

* le was a and Saw the Fest tives. Lialked
Threw the apex  ¢kler Brought Ft 5

aaa 7] °
oan _clethes No prs te 3

Name or Social Security Number of First Petitioner: _*



D2

D3

D4
D5
D6

D.7

Special Exposure Cohort Petition U.S. Department of Health and Human Services

for Disease Control and Prevention
National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 95/31/2007

Labor Organization Information:

Name of Organization

Position of Contact Person
Name of Petition Representative:

Address of Petition Representative:

Street Apt # P.O. Box

City State Zip Code
Telephone Number of Petition Representative: ) :
Email Address of Petition Representative:

Period during which labor organization represented employees covered by this petition
(please attach documentation): Start _ End

Identity of other labor organizations that may represent or have represented this class of
employees (if known):



B4
BS
B.6

C.2

C3
C4

C5
Cé

C7
C7a

C.7b
C7c

-4o.7d—-

Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control! and Prevention
liness Compensation Act National institute for Occupational Safety and Health

ecial ure Cohort Petition — Form B

OMB Number: 0920-0639 Expires: 05/31/2007
of 7

‘on ~—- Complete S
Name of Survivor:

MrJ/Mis/Ms. First Name Middle Initial Last Name
Social Security Number of Survivor:
Address of Survivor:

Street Apt# P.0. Box

City State Zip Code
Telephone Number of Survivor: ) :
Email Address of Survivor:

Relationship to Employee: Q Spouse Q Son/Daughter Q Parent
Q Grandparent Q Grandchild

Information — Comer on © Ub ou are a labor organization.
Name of Employee:
MrJNirs/Ms, First Name Middie Initial Last Name

Former Name of Employee (e.g., maiden name/legal name change/other):

MrJMrs./Ms. First Name Middle Initial Last Name
Social Security Number of Employee:
Address of Employee (if living):

Street Apt # P.O. Box

r -_
City State Zip Code

Telephone Number of Employee: Pre nr L-

Email Address of Employee: —

Employment Information Retated to Patitinn-
Employee Number (if known):

Dates of Employment: Start ~ End _ an

Employer Name: —MASON_& HANGER __-ST LAS. MASON COMPANY
Work Site Location: -__ MIDDLETOWN —TowA-— > = = = — —_——
IOP _aka TAAP aka BAECP

Supervisors Name: —e

se tO


Special Exposure Cohort Petition ‘ . U.S. Department of Health and Human Services | :
under the Energy Employees Occupational Centers for Disease Control and Prevention | :
lliness Compensation Act National Institute for Occupational Safety and Health | :

OMB Number: 0920-0639 Expires: 05/31/2007 :

Special Exposure Cohort Petition — Form B Appendix — Continuation Page | ©
Continuation Page — Photocopy and complete as necessary. :

The frequency and/or results of urine testing is not available.

The relationship of urine sampling time in relation to time at exposure was also not
documented.

_ Surrogate information for internal dosimetry such as records from air monitor
measurements or contamination monitors are non existent.

There is some qualitative data regarding removable radioactive contamination both from
various indoor work sites on Line 1 swiped in June 2000, and more worrisome, pages of
historically positive swipe tests from the containers in which the pits arrived. There are also
records on the site documenting that soil was tested for plutonium contamination, however
results of these tests have not been found.

However, given this information -

« No documentation has been found that nasal smears were ever taken for plutonium, or
any other radionuclide, to assess possible inhalation.
No documentation has been found documenting the results from in vivo measurements.
No documentation has been found that urine or fecal analyses were performed for
plutonium or other radionuclide.

e Nu documentation is found regarding the solubility of the potential inhaled or ingested
compounds.

« Personal employee records do not contain external dose in the vast majority of cases
and internal dose data has not appeared in any records reviewed.

The majority of the exposed work force was not routinely monitored, especially prior to
1968. IT appears that throughout the history of the facilities’ operations, radiation
monitoring was inadequate in that neutron radiation monitoring was not performed;
biological monitoring (urine, nasal swabs, etc.) was not performed; no extremity
monitoring (ring or bracelet monitors) was performed.

Several area monitoring levels indicate exposure levels at the wall which exceed OSHA
exposure limits and the proximity of workers to pits and weapons would be expected to be
much closer than the area monitors were to the radioactive materials. Entire workforces
(job groups) were not monitored at all including guards, disassembly workers and other
respondents from the cohort who report working with pits but never being monitored. The
adequacy of the badges used is called into question by the lack of available SOPs, QA and
validation data and personal discussion with senior health physicists.

Name and social security number of first petitioner’
Page 6 of 8 pages


Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
itiness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 2 of 7

Survivor information — Complete Section B if you are a Survivor or representing a Survivor.
B19 Namoof Survivar- -

NILVIISVIS. SUING ~ ‘Middle Initial Last Name
B2 Social Security Number of Survivor:
B.3 Address of Survivor:

Stee. -- Anti P.O. Box

— - ~ grate ae wes
B.4 Telephone Number of Survivor: ¢
B5 Email Address of Survivor:

B.6 Relationship to Employee: QO Spouse O Son/Daughter @ Parent
Q Grandparent Q Grandchild

Employee Infor ion — Complete Section C UNLE
com Name af Bemmtasenns

SS you are a labor organization.

MrJMrsums. rirst Name Middle Initial / LastName

C2 Former Name of Employee (¢.g., maiden name/legal name change/other):
wane

Mr/Mrs./Ms. -. First Name Middle Initial” Last Name
C3 Social Security Number of Employee: i

C.4 Address of Employee (if living):
les
Street Apt# P.O. Box

City State Zip Code
C5 Telephone Number of Employee: ) -
C.6 Email Address of Employee:

C.7 Employment Information Related to Petit'--~
C.7a Employee Number (if known):

C.7b Dates of Employment: Start Aenean | End Cd
C.7c Employer Name: To mic Energy Comission, Flay t LAA
C.7d WorkSite Location: LZidd Se Toman Fa -

C.7e Supervisor's Name: =

lus *

Name or Social Security Number of First Petitioner: _